Notice: Function _load_textdomain_just_in_time was called incorrectly. Translation loading for the wp-migrate-db domain was triggered too early. This is usually an indicator for some code in the plugin or theme running too early. Translations should be loaded at the init action or later. Please see Debugging in WordPress for more information. (This message was added in version 6.7.0.) in /srv/app/gotoiba-dev/htdocs/web/wp-includes/functions.php on line 6121
We were advised that our software will need to be updated so that FICO credit scores and debt service coverage ratio (DSCR) data will be reported under a new regulation taking effect in 2020. Is this accurate, and does the regulation relate to Home Mortgage Disclosure Act (HMDA) reporting or credit reporting? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We were advised that our software will need to be updated so that FICO credit scores and debt service coverage ratio (DSCR) data will be reported under a new regulation taking effect in 2020. Is this accurate, and does the regulation relate to Home Mortgage Disclosure Act (HMDA) reporting or credit reporting?

—

by

We are not aware of any regulatory changes in 2020 relating to the reporting of FICO credit scores or DSCR data. The recent HMDA rule changes do include new credit score and debt-to-income ratio reporting requirements for certain institutions, but those provisions have been in effect since January 1, 2018. The only remaining provisions from the HMDA rule that will go into effect in 2020 are the quarterly filing requirements for institutions with at least 60,000 covered loans and applications in the preceding calendar year.

For resources related to our guidance, please see:

  • CFPB HMDA Rule Key Dates Timeline (Showing an effective date of January 1, 2018, for “most provisions related to institutional and transactional coverage, and data collection, recording, reporting, and disclosure.”)
  • Regulation C, 12 CFR 1003.5(a)(1)(ii) (as effective January 1, 2020) (“Quarterly reporting. Within 60 calendar days after the end of each calendar quarter except the fourth quarter, a financial institution that reported for the preceding calendar year at least 60,000 covered loans and applications, combined, excluding purchased covered loans, shall submit to the appropriate Federal agency its loan/application register containing all data required to be recorded for that quarter pursuant to § 1003.4(f). The financial institution shall submit its quarterly loan/application register pursuant to this paragraph (a)(1)(ii) in electronic format at the address identified by the appropriate Federal agency for the institution.”)